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Regs., provides that a qualified offer “specifies the offered
amount if it clearly specifies the amount for the liability of
the taxpayer * * *. The offer may be a specific dollar amount of
the total liability or a percentage of the adjustments at issue
in the proceeding at the time the offer is made.” The specified
amount “must be an amount, the acceptance of which by the United
States will fully resolve the taxpayer's liability, and only that
liability * * * for the type or types of tax and the taxable year
or years at issue in the proceeding.” Id.
Petitioner sent respondent a letter for each of the years at
issue offering to settle the case. Petitioner’s offers included
the following terms of settlement for each year:
1. Any adjustment the Service proposes to make
with respect to the [1985] joint tax return filed by
taxpayer and her husband shall not be made with respect
to Rhita S. Lippitz.
2. The taxpayer shall be granted relief from any
additional joint liability, in its entirety, pursuant
to IRC § 6015(c).
3. Solely for purposes of this qualified offer,
Rhita S. Lippitz shall make a payment of $100.00
against any final adjustment determined by Decision or
Stipulation with respect to the joint tax return for
the [1985] tax year.
4. No other adjustments shall be made in
connection with the [1985] income tax return as it
relates to Rhita S. Lippitz.
We find petitioner’s offer to clearly state the amount offered.
Petitioner offered to settle each docketed case for relief from
any additional joint liability pursuant to section 6015(c). In
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Last modified: November 10, 2007